The Data Protection Act 2018 (“DPA 2018”) and the General Data Protection Regulation (“GDPR”) impose certain legal obligations in connection with the processing of personal data. This privacy notice informs you about how we process information that we record about you, whether provided by you, or by another person or organisation. It applies to information that could identify you as an individual (“personal information”) and information that does not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
Armstrong Private Client Solicitors Ltd is a data controller within the meaning of the GDPR and we process personal data. The firm’s contact details are as follows:
Armstrong Private Client Solicitors Ltd
143 Stoke Newington Church Street
Email: firstname.lastname@example.org (admin null@null armstrongprivateclient NULL.com)
Telephone: 020 7254 1950
We are committed to the protection of your privacy and confidentiality. We recognise that you are entitled to know that your data will not be used for any unintended purpose and will not accidentally fall into the hands of a third party.
We may amend this privacy notice from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended privacy notice.
We intend to process personal data for the following purposes:
- To enable us to supply professional services to you as our
- To fulfil our obligations under relevant laws in force from time to time (e.g. the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”)).
- To comply with professional obligations to which we are subject as a member of The Law Society of England and Wales.
- To use in the investigation and/or defence of potential complaints, disciplinary proceedings and legal proceedings.
- To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
- To contact you about other services we provide which may be of interest to you if you have consented to us doing so.
We may collect and process the following information about you when you fill in a form on our website or contact us for further advice. If you contact us, we may keep a record of that correspondence.
- Your name
- Your address
- Your email address
- Other information relevant to any customer surveys and/or offers.
Our intended processing of personal data has the following legal bases:
- At the time you instructed us to act, you gave consent to our processing your personal data for the purposes listed above.
- The processing is necessary for the performance of our contract with you.
- The processing is necessary for compliance with legal obligations to which we are subject (e.g. MLR 2017).
- The processing is necessary for the purposes of the following legitimate interests which we pursue:.
- Record-keeping for the proper and necessary administration of our business;
- Responding to communications from you to which we believe you would expect a response;
- Protecting and asserting the legal rights of any party;
- Insuring against or obtaining professional advice that is required to manage business risk;
- Protecting your interests where we believe we have a duty to do so.
It is a requirement of our contract with you that you provide us with the personal data that we request. If you do not provide the information that we request, we may not be able to provide professional services to you. If this is the case, we will not be able to commence acting or will need to cease to act.
- Identity data – this includes full name, title, date of birth, gender and marital status.
- Contact data – this is the data we use to contact you, including your home address, email address and telephone numbers.
- Financial data – this is the data we use to send and receive any payments from you, i.e. bank account and payment card details.
- Transaction data – this includes details about payments to and from you and other details of services you have purchased from us.
- Technical data – this includes your internet protocol (IP), details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and geographical location.
- Marketing and communications data – your preferences in receiving marketing from us and our third parties and your communication preferences.
- Open Data and Public Records – information about you that is in public records, such as Companies House or the Land Registry, and information that is openly available on the internet.
We may also on occasion collect sensitive (or special categories of) personal data. Sensitive personal data is defined by data protection laws to include personal data revealing a person’s racial or ethnic origin, religious or philosophical beliefs, or data concerning health. If we do collect sensitive personal data, we will not process it without your specific consent.
We may share your personal data with:
- any third parties with whom you require or permit us to correspond
- an alternate appointed by us in the event of incapacity or death
- tax insurance providers
- professional indemnity insurers
- our professional body, The Law Society of England and Wales and/or the Office of Professional Body Anti-Money Laundering Supervisors (OPBAS) in relation to practice assurance and/or the requirements of MLR 2017 (or any similar legislation)
- Certainty National Will Register
If the law allows or requires us to do so, we may share your personal data with:
- the police and law enforcement agencies
- courts and tribunals
- the Information Commissioner’s Office (“ICO”)
We may need to share your personal data with the third parties identified above in order to comply with our legal obligations, including our legal obligations to you. If you ask us not to share your personal data with such third parties we may need to cease to act.
Your personal data will be processed in the EEA only.
- Communicating with you
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
- Dealing with complaints
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person.
- Email marketing
For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing.
Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to opt out of receiving email marketing communications from us at any time by:
- contacting our Data Controller using the contact details set out above; or
- using the “unsubscribe” link in emails.
- Customer relationship management system
We use a customer relationship management (CRM) system to process personal data.
Data subjects include existing, former and prospective clients and their agents and representatives.
Personal data that we process includes the name of the person, information about his or her employer and job position, and contact information.
We process this data on the basis of consent for purposes that include:
- managing and developing our business or services
- informing clients and prospective clients about our services
- determining relationships between clients and our partners and employees
- analysing whether we provide clients with a high level of service
We do not sell or share any personal data with third parties unless we have explicit consent to do so from the data subject.
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in our site
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed and for the purposes of satisfying any legal, accounting, or reporting requirements.
The criteria we use for retaining different types of personal data, includes the following:
- General queries – when you make an enquiry or contact us by email or telephone, we will retain your information for as long as necessary to respond to your queries. After this period, we will not hold your personal data for longer than one year if we have not had any active subsequent contact with you;
- Direct marketing – where we hold your personal data on our database for direct marketing purposes, we will retain your information for no longer than two years if we have not had any active subsequent contact with you.
- Legal and regulatory requirements – we may need to retain personal data for up seven years after we cease providing services and products to you where necessary to comply with our legal obligations, resolve disputes or enforce our terms and conditions.
You are responsible for retaining information that we send to you and this will be supplied in the form agreed between us. Documents and records relevant to your tax affairs are required by law to be retained by you as follows:
- Individuals, trustees and partnerships with trading or rental income: five years and 10 months after the end of the tax year; otherwise: 22 months after the end of the tax
- Companies, LLPs and other corporate entities: six years from the end of the accounting
Where we act as a data processor as defined in DPA 2018, we will delete or return all personal data to the data controller as agreed with the controller at the termination of the contract.
You have a right to request access to your personal data that we hold. Such requests are known as ‘subject access requests’ (“SARs”).
Please provide all SARs in writing marked for the attention of Alison Armstrong.
To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information. For example, you should tell us:
- your date of birth
- previous or other name(s) you have used
- your previous addresses in the past five years
- personal reference number(s) that we may have given you, for example your national insurance number, your tax reference number or your VAT registration number
- what type of information you want to know
If you do not have a national insurance number, you must send a copy of:
- the back page of your passport or a copy of your driving licence; and
- a recent utility bill.
DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request).
We will not charge you for dealing with a SAR.
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorise the person concerned to write to us for information about you, and/or receive our reply.
Where you are a data controller and we act for you as a data processor (e.g. by processing payroll), we will assist you with SARs on the same basis as is set out above.
You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed. Should
you become aware that any personal data that we hold about you is inaccurate and/or incomplete, please inform us immediately so we can correct and/or complete it.
In certain circumstances you have a right to have the personal data that we hold about you erased. Further information is available on the ICO website (www.ico.org.uk (http://www NULL.ico NULL.org NULL.uk/)). If you would like your personal data to be erased, please inform us immediately and we will consider your request. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.
In certain circumstances you have the right to ‘block’ or suppress the processing of personal data or to object to the processing of that information. Further information is available on the ICO website (www.ico.org.uk (http://www NULL.ico NULL.org NULL.uk/)). Please inform us immediately if you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.
In certain circumstances you have the right to be provided with the personal data that we hold about you in a machine-readable format, e.g. so that the data can easily be provided to a new professional adviser. Further information is available on the ICO website (www.ico.org.uk (http://www NULL.ico NULL.org NULL.uk/)).
The right to data portability only applies:
- to personal data an individual has provided to a controller;
- where the processing is based on the individual’s consent or for the performance of a contract; and
- when processing is carried out by automated means
We will respond to any data portability requests made to us without undue delay and within one month. We may extend the period by a further two months where the request is complex or a number of requests are received but we will inform you within one month of the receipt of the request and explain why the extension is necessary.
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent.
- the withdrawal of consent does not affect the lawfulness of earlier processing
- if you withdraw your consent, we may not be able to continue to provide services to you
- even if you withdraw your consent, it may remain lawful for us to process your data on another legal basis (e.g. because we have a legal obligation to continue to process your data)
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.